About Triniti Communications

TrinitiComm

Your Privacy Is Serious Business To Us

At Triniti Communitcations Intl. Ltd. (TrinitiComm), we respect our customers' privacy to the fullest. That is why we have adopted the Federal Trade Commission's "Model Code for the Protection of Personal Information" as the basis for our own Privacy Policy. The following are principles that govern the collection, use and disclosure of our customers' personal information:

Why we collect personal information

If you are a TrinitiComm customer, TrinitiComm has some basic information about you. We understand that some of this information is private, which is why we collect personal information only for the following purposes:

1. To establish and maintain a responsible commercial relationship with you and to provide ongoing service. For example, when you apply for service, we collect information that allows us to confirm your identity and credit history so that we can accurately bill and collect for the products and services that you receive from us. We may collect credit card or bank account information, if you prefer the convenience of pre-authorized payment for services.

2. To understand your needs and preferences. We maintain a record of the products and services you receive from us, and we may ask for additional information so that we can serve you better. For example, we will ask for your e-mail address, if you wish to pay your bills electronically.

3. To develop, enhance, market or provide products and services. For example, we look at how our customers use our products and services, so that we can understand how to improve them. From time to time, we may review and analyze your use of our products and services to help us provide better product recommendations and special offers that we think will interest you.

4. To manage and develop our business and operations. For example, we analyze customer usage of our networks and facilities to help us manage them efficiently and plan for future growth.

5. To meet legal and regulatory requirements. For example, we may collect information in response to a court order, or to satisfy a request by the Federal Communications Commission (the "FCC") for information about a customer complaint and how it was resolved.

When do we disclose personal information?

There is a variety of circumstances where we may need to disclose some personal information about our customers. Here are some examples:

1. We may disclose a customer's personal information to a person who, in the reasonable judgement of TrinitiComm, is seeking the information as an agent of the customer. For example, we may provide information about a customer's account to the customer's legal representative if we are satisfied that that individual is requesting the information on behalf of the customer.

2. Customer information may be shared among TrinitiComm business units to help us serve our customers better and to provide them with services from different parts of our organization.

3. We may disclose a customer's personal information to:

a. another telecommunications company for the efficient and cost-effective provision of telecommunications services;
b. a company involved in supplying the customer with communications or communications directory related services;
c. a company or individual employed by TrinitiComm to perform functions on its behalf, such as research or data processing; or
d. an agent used by TrinitiComm to evaluate the customer's credit worthiness or to collect the customer's account.

Any such disclosure of a customer's personal information outside of TrinitiComm is made on a confidential basis with the information to be used only for the purpose for which it was disclosed.

4. We may disclose a customer's personal information to a credit reporting agency.

5. We may disclose a customer's personal information to a public authority or agent of a public authority, if in the reasonable judgement of TrinitiComm, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information.

6. In conjunction with special offers or programs, we may disclose customers' personal information to our program partners, or to third-party agents responsible for administering such offers or programs. Any such disclosure is made on a confidential basis with the customer's express consent.

How do we protect your personal information?

In order to protect your personal information and your right to privacy, TrinitiComm:

1. will not collect, use or disclose your personal information for any purpose other than those identified above, except with your consent;

3. will protect the confidentiality of your personal information when dealing with other companies;

4. will strive to keep your personal information as accurate and up-to-date as is necessary for the purposes identified above; and

5. will honour any request you may make for access to your personal information.

What are your choices?

We would like to have your consent to continue to collect, use and disclose your personal information for the purposes identified above. However, you do have choices and can refuse or withdraw your consent as follows:

1. You may have your name removed from our telephone, mail or e-mail marketing lists. We use these lists to inform you of relevant products, services and special offers that may be of benefit to you.

2 Telephone directory publisher such as, YellowPages™, makes available lists of published names, addresses and phone numbers to selected organizations for a fee. You may choose to be excluded from these lists (non-published names, addresses and phone numbers are automatically excluded).

3. You may refuse to provide personal information to us. You may also withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. However, in either case, this may limit our ability to serve you.

If you have any questions or concerns about our privacy practices, please feel free to contact us. Otherwise, we will assume that we have your consent to continue to collect, use and disclose your personal information for the purposes identified above.

Privacy Policy

This Policy describes TrinitiComm's collection, use and/or disclosure of personal information. It governs the behavior of employees and agents acting on TrinitiComm's behalf when dealing with personal information. It provides procedures for an individual's access to and correction of personal information.

TrinitiComm is responsible for personal information under its control and will designate an individual or individuals who are accountable for the organization's compliance with the following principles.

1.1 Accountability for TrinitiComm's compliance with the principles rests with the senior management of TrinitiComm and the person or persons designated by senior management as Privacy Officer, even though other individuals within the organization may be responsible for the day-to-day collection and processing of personal information. In addition, other individuals within the organization may be delegated to act on behalf of senior management or the Privacy Officer.

1.2 TrinitiComm's senior management has designated the following person to act as Privacy Officer to oversee the organization's compliance with the principles:

1.3 TrinitiComm is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing. TrinitiComm will use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.

1.4 TrinitiComm will implement policies and practices to give effect to the principles, including:

TrinitiComm will identify the purposes for which personal information is collected at or before the time the information is collected.

2.1 TrinitiComm collects personal information only for the following purposes ("identified purposes"):

(a) to provide service(s) and/or products to its customers;
(b) to maintain commercial relations and to communicate with its customers (which will include, but not be limited to: billing, collection, advertising, promotion, account verification);
(c) to identify customer needs and/or preferences;
(d) to meet legal and regulatory requirements;
(e) to administer and manage its business operations

2.2 TrinitiComm will provide notice of the identified purposes either orally, electronically or writing prior to or at the time of collection of the personal information.

2.3 Persons collecting personal information will be able to explain to individuals the purposes for which the information is being collected, or will refer the individual to a designated person at TrinitiComm who will explain the purposes.

2.4 When personal information that has been collected is to be used for a purpose not previously identified, the new purpose will be identified prior to use. Unless the new purpose is required by law, TrinitiComm will obtain the consent of the individual before information is used for that new purpose.

Occasionally, TrinitiComm will communicate to you special bonus and new product offers that we think may be of value to you. If you wish to opt-out of receiving targeted communications from TrinitiComm in electronic, printed or verbal format (other than information included with your monthly bills), simply inform us in writing at Privacy Office, PO Box 36695, Canton, OH 44735

PRINCIPLE #3 - CONSENT

The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where inappropriate.

3.1 In certain circumstances, personal information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal, medical or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information. Seeking consent may be impossible or inappropriate when there is an emergency threatening the individual's life, health or security, or where the individual is a minor, seriously ill, or mentally incapacitated. In other instances, information may be publicly available. Moreover, TrinitiComm may provide personal information to its lawyer or agent to collect a debt, comply with a subpoena, warrant or other court order, government institution requesting the information upon lawful authority, or as may be otherwise required by law.

3.2 TrinitiComm will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when TrinitiComm wants to use information for a purpose not previously identified).

3.3 TrinitiComm will make a reasonable effort to ensure that the individual is advised of the purposes for which the information will be used. To make the consent meaningful, the purposes will be Stated in such a manner that the individual can reasonably understand how the information will be used or disclosed.

3.4 TrinitiComm will not, as a condition of the supply of a product or service, require an individual to consent to the collection, use, or disclosure of information beyond that required to fulfil the explicitly specified and legitimate purposes.

3.5 The form of consent sought by TrinitiComm may vary, depending upon the circumstances and the type of information disclosed. In determining the form of consent to use, TrinitiComm will take into account the sensitivity of the information and the reasonable expectations of the individual. An authorized representative (such as a legal guardian or a person having power of attorney) can also give consent.

TrinitiComm will seek express consent when the information is likely to be considered sensitive.

Implied consent will generally be appropriate when the information is less sensitive. The use of services or products by a customer or the acceptance of employment by an employee will be considered implied consent to collect, use and disclose personal information for all identified purposes.

3.6 An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. TrinitiComm will inform the individual of the implications of such withdrawal. In order to withdraw consent, an individual must provide notice to TrinitiComm in writing.

3.7 With respect to personal information already collected by TrinitiComm prior to the publication of this Privacy Policy, this Policy will constitute reasonable notice to TrinitiComm's current customers and employees of the purposes and uses for which such personal information has been collected. Should an individual object to these ongoing uses or disclosures, consent may be withdrawn upon providing notice to TrinitiComm in writing.

PRINCIPLE #4 - LIMITING COLLECTION
The collection of personal information will be limited to that which is necessary for the purposes identified by TrinitiComm. Information will be collected by fair and lawful means.

4.1 TrinitiComm collects personal information from its customers and employees for the purposes described under Principle #2.

4.2 TrinitiComm may also collect personal information from such third parties as credit bureaus, employers or personal references or other third parties that represent that they have the right to disclose the information.

4.3 In connection with its Internet business, TrinitiComm may use a 'Cookie' to collect certain information which it uses to track user patterns on its web site(s). A Cookie is a text file containing a unique identification number that identifies a user's browser, but not a particular individual. A Cookie does not identify an individual. Furthermore, TrinitiComm does not use Cookies in combination with other information to obtain personally identifiable information. If an individual does not wish to use Cookies, he or she can re-set their browser to either provide notification or refuse to accept Cookies.

PRINCIPLE #5 - LIMITING USE, DISCLOSURE, AND RETENTION

Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.

5.1 TrinitiComm may collect, use or disclose personal information without the individual's knowledge or consent in certain circumstances as described in Principle #3.1.

5.2 TrinitiComm may disclose a customer's personal information to:

(a) another telecommunication company for the provision of telecommunications services to that customer;
(b) a company involved in providing communications directory services;
(c) a person involved in the development, promotion, marketing or enhancement of TrinitiComm services;
(d) a credit collections agency;
(e) emergency services in an emergency situation;
(f) a person, who, in the reasonable estimation of TrinitiComm, is an agent of the customer;
(g) any other third party, upon receiving the consent of the customer or as required by law.

5.3 TrinitiComm may disclose an employee's personal information in the following circumstances:

(a) in the administration of that employee's benefits;
(b) in providing references to prospective employers, upon receiving the consent of the employee;
(c) as may be required by law.

5.4 Certain TrinitiComm employees may be given access to customer and/or employee information in so far as their duties require access for business purposes. TrinitiComm employees are governed by a non-disclosure agreement prohibiting disclosure or use of any confidential or personal information for any purposes other than the Stated business purposes.

5.5 TrinitiComm will retain personal information for only as long as required to fulfil the identified purposes or as required by law.

5.6 Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by TrinitiComm.

PRINCIPLE #6 - ACCURACY

Personal information will be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

6.1 The extent to which personal information will be accurate, complete, and up-to-date will depend upon the use of the information, taking into account the interests of the individual. Information will be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about the individual.

6.2 TrinitiComm will not routinely update personal information unless such a process is necessary to fulfil the purposes for which the information was collected.

6.3 Personal information that is used on an ongoing basis, including information that is disclosed to third parties, should generally be accurate and up-to-date, unless limits to the requirement for accuracy are clearly set out.

PRINCIPLE #7 - SAFEGUARDS

Personal information will be protected by security safeguards appropriate to the sensitivity of the information.

7.1 TrinitiComm will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution and format of the information, and the method of storage.

7.2 TrinitiComm protects all personal information regardless of the format in which it is held. The methods of protection include:

(a) physical measures, such as locked filing cabinets and restricted access to offices;
(b) organizational measures, such as security clearances and limiting access on a "need to know" basis;
(c) technological measures, such as the use of passwords and encryption.

7.3 TrinitiComm makes their employees aware of the importance of maintaining the confidentiality of personal information. TrinitiComm employees are governed by a non-disclosure agreement prohibiting disclosure or use of any confidential or personal information for any purposes other than the Stated business purposes.

7.4 TrinitiComm will use care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.

PRINCIPLE #8 - OPENNESS

TrinitiComm will make readily available to individuals specific information about its policies and practices relating to the management of personal information.

8.1 TrinitiComm will make its policies and practices with respect to the management of personal information easily comprehensible and accessible, by providing upon request:

(a) the name, title, and address of the Privacy Officer accountable for TrinitiComm's policies and practices and to whom complaints or inquiries can be forwarded;
(b) the means of gaining access to personal information held by TrinitiComm; and
(c) a description of the type of information held by TrinitiComm and/or its subsidiaries, including a general account of its use.

8.2 TrinitiComm will make this Privacy Policy available online, by mail, or in a brochure format at its place of business. Furthermore, TrinitiComm's Customer Services Representatives will be trained to answer requests at TrinitiComm's toll-free customer service telephone number.

PRINCIPLE #9 - INDIVIDUAL ACCESS

Upon request, an individual will be informed of the existence, use, and disclosure of his or her personal information and will be given access to that information. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

9.1 Upon request, TrinitiComm will inform an individual whether or not the organization holds personal information about the individual, and will provide that individual with a reasonable opportunity to review the personal information in his or her file.

9.2 TrinitiComm will allow the individual access to his or her personal information once the individual has provided TrinitiComm with a written request application. TrinitiComm will make the application available to customers through Customer Service Representatives and to employees through the Human Resources Department. The application will include sufficient information to permit TrinitiComm to provide an account of the existence, use, and disclosure to any third parties of this personal information. TrinitiComm will use the application only for this purpose.

9.3 TrinitiComm will respond to an application for individual access to personal information within a reasonable time and at minimal or no cost to the individual. The requested information will be provided or made available in a form that is generally understandable.

9.4 TrinitiComm will be as specific as possible in providing an account of third parties to which it has disclosed personal information about an individual. When it is not possible to provide a list of the organizations to which it has actually disclosed information about an individual, TrinitiComm will provide a list of organizations to which it may have disclosed information about the individual.

9.5 In certain instances, TrinitiComm will not be able to provide the individual access to his or her personal information. For example, TrinitiComm will not provide access to information where the information requested is prohibitively costly to provide; where the information contains references to other individuals; where the information cannot be disclosed for legal, security or commercial proprietary reasons; where the information is subject to solicitor-client or litigation privilege; or where the information can best be available from another source (for example, through a medical practitioner). In each case, TrinitiComm will provide reasons for denying any access to personal information.

9.6 When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, TrinitiComm will amend the information as required. Depending upon the nature of the information challenged, amendment involves the correction, deletion or addition of information. Where appropriate, the amended information will be transmitted to third parties having access to the information in question.

9.7 When a challenge is not resolved to the satisfaction of the individual, TrinitiComm will record the substance of the unresolved challenge. When appropriate, the existence of the unresolved challenge will be transmitted to third parties having access to the information in question.

PRINCIPLE #10 - CHALLENGING COMPLIANCE

An individual will be able to address a challenge concerning compliance with the above principles to TrinitiComm's Privacy Officer.

10.1 TrinitiComm will maintain procedures to receive and respond to complaints or inquiries about its policies and practices relating to the handling of personal information. TrinitiComm will make every effort to ensure that its procedures are easily accessible and simple to use.

10.2 TrinitiComm will inform individuals who make inquiries or lodge complaints of the existence of relevant complaint procedures.

10.3 The person or persons accountable for compliance with this Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

10.4 TrinitiComm will investigate all complaints. If a complaint is found to be justified, TrinitiComm will take appropriate measures, including, if necessary, amending its policies and practices.

The Personal Information Protection and Electronic Documents Act governs the collection, use and disclosure of personal information in the commercial sector.

Under the Act, TrinitiComm is required to adhere to ten privacy principles set out in the National Standard of Canada, Model Code for the Protection of Personal Information.